Laureys v. Commissioner
United States Tax Court
P, a member of the CBOE and an appointed market maker in certain CBOE options, engaged in various option spread transactions. Held, offsetting positions in options do not constitute a "similar arrangement" under sec. 465(b)(4), I.R.C. 1954, as amended.
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P, a member of the CBOE and an appointed market maker in certain CBOE options, engaged in various option spread transactions. Held, offsetting positions in options do not constitute a "similar arrangement" under sec. 465(b)(4), I.R.C. 1954, as amended. Held, further, R's expert report would not be received in evidence; P entered into the transactions for the primary purpose of profit; the transactions were for P's own account and were not dealer activity eligible for ordinary loss treatment.
1Opinion of the Court
Frank J. Laureys, Jr., and Carol J. Laureys, Petitioners v. Commissioner of Internal Revenue, Respondent
Laureys v. Commissioner
Docket No. 23490-85
United States Tax Court
92 T.C. 101; 1989 U.S. Tax Ct. LEXIS 6; 92 T.C. No. 8;
January 25, 1989; As amended February 8, 1989; As amended February 28, 1989 January 25, 1989, Filed
Decision will be entered under Rule 155.
P, a member of the CBOE and an appointed market maker in certain CBOE options, engaged in various option spread transactions. Held, offsetting positions in options do not constitute a "similar arrangement" under sec. 465(b)(4), I.R.C.…
2Cases cited38 opinions
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
- Marx & Co. v. Diners' Club, Inc.Court of Appeals for the Second Circuit · 1977
- Messing v. CommissionerUnited States Tax Court · 1967
- Glass v. CommissionerUnited States Tax Court · 1986
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